MVA White Collar Defense, Investigations, and Regulatory Advice Blog

On October 4, 2023, Deputy Attorney General Lisa Monaco announced the next (but not final) chapter of the U.S. Department of Justice’s concerted attempt to promote voluntary corporate self-disclosure of misconduct with a new Mergers & Acquisitions Safe Harbor Policy.

Background

The DOJ in recent years has expressed a commitment to creating clear, predicable, and standardized policies that incentivize companies to voluntarily self-disclose misconduct to the government, which the Department describes as the “clearest path for a company to avoid a guilty plea or an ...

On March 17, 2022, FINRA issued Regulatory Notice 22-10 (“Notice”), which reminds FINRA member firms and their associated persons of the scope of supervisory liability for Chief Compliance Officers (“CCO”). The Notice discusses this liability in the context of FINRA Rule 3110, which among other things, requires FINRA member firms to establish and maintain a system (including written procedures) to supervise the activities of each associated person in a manner that is reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA ...